- Site: Hinkley Point C
- IR number: 21-013
- Date: July 2021
- LC numbers: 17
Executive summary
Purpose of Intervention
In accordance with the Office for Nuclear Regulation’s (ONR’s) Hinkley Point C (HPC) Construction inspection plan, ONR performs a series of planned compliance inspections of identified licence conditions, to ensure that NNB Generation Company (HPC) Ltd (NNB GenCo) is proportionately and adequately developing and implementing its licence compliance arrangements commensurate to the current stage of the project.
The purpose of this intervention was to gain confidence that NNB GenCo’s current management system arrangements and interface with the Mechanical, Electrical and HVAC Alliance (MEHA) are adequately implemented, effective and integrated.
Interventions Carried Out by ONR
ONR conducted a Licence Condition (LC) 17 (Management Systems) compliance inspection targeted on the quality management arrangements. This involved sampling the deployment of the management system arrangements, including the Assurance, Audit and Self-assessment programmes to confirm they are adequately testing the management system arrangements, associated with MEHA.
ONR assessed NNB GenCo’s LC arrangements against relevant good practice, which included ONR regulatory guidance, specifically relevant Technical Inspection Guides and Technical Assessment Guides.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
Based on the discussions and evidence provided during the intervention, ONR observed examples of integration and collaboration within the MEHA Quality Function, with further enhancements planned during 2021.
From the evidence sampled and discussions held, the MEHA have identified, and are in the process of addressing, the key issues and challenges facing the effective implementation of the MEHA quality function.
ONR recognised that improvements have been made to the MEHA management system arrangements, However, some arrangements are still to be fully developed and implemented.
Whilst the MEHA has made progress in developing the management system arrangements, there is no single plan for the future development, which demonstrates what needs to be done, by whom and by when.
There was clear evidence of the MEHA retrospectively implementing Lifetime Quality Records (LTQR) specification revision 2, in addition to a clear commitment that the specification will be included on all new MEHA contracts.
ONR noted that the MEHA deployment and update of Project Quality Control Plans (PCQP) requires improvement. From the information sampled, the MEHA do not currently have adequate deployment of the PQCPs. Noting this shortfall is already being monitored by an extant ONR regulatory issue.
ONR observed that the MEHA are actively seeking to utilise internal and external Learning from Experience (LfE) to increase the effectiveness and efficiency of the MEHA management system arrangements.
Conclusion of Intervention
Overall, ONR concluded that an inspection rating of AMBER, seek improvement, is appropriate. A number of areas of good practice were highlighted, but improvement is required against specific areas.
The key area of improvement relating to the deployment and update of PQCP’s is actively being addressed by an extant regulatory issue. Hence, a new issue will not be raised following this intervention.